Compliance with statutory provisions and internal guidelines is the basis of our business. Responsible action by all corporate bodies, managers and employees in accordance with the law is essential for the success of our company and for retaining the confidence of our customers and business partners. For this reason, VNG has established a comprehensive compliance management system which includes the classical approaches of prevention, detection and appropriate reaction with respect to infringements of laws and internal regulations. The objective is to make compliance with statutory requirements and internal guidelines an integral part of the thinking and action of all corporate bodies, managers and employees and to strengthen the confidence of business partners and shareholders in the company. In order to ensure that these objectives are achieved, the VNG Group provides regular training sessions and e-learning programs on general compliance topics and the code of conduct.
The central Compliance function of the VNG Group, which consists of the Compliance Officer Mr. Olaf Zwetkow and the Deputy Compliance Officer Ms. Cornelia Müller-Pagel, coordinates measures throughout the Group for the prevention of corruption and infringements of competition law as well as compliance with regulatory requirements. The Compliance Officer reports direct to the Executive Board and is supported by the decentralized compliance managers in the individual companies of the VNG Group. These compliance managers meet once per year at the compliance manager conference to exchange information. The mission statement and code of conduct of the VNG Group lay the foundation for the compliance organization.
Code of conduct
The code of conduct is based on the mission statement of the VNG Group, i.e. on the basic principles to which the Group is committed. The standards laid down in our code of conduct play a key role in determining our relations with business partners, shareholders, employees and society as a whole. The code of conduct not only provides basic orientation but also sets out a framework for action and gives an overview of the key statutory requirements and internal guidelines that apply.
Dealing with presents and invitations
Within the VNG Group, presents, entertainment and invitations must be dealt with in accordance with the principles of compliance, responsibility and appropriateness. Further specific requirements are laid down in Group guidelines for presents, invitations and entertainment expenses. These guidelines also state value limits and qualitative criteria. If the value of any presents, entertainment expenses or invitations exceeds the limits which are set, the approval of Compliance must be obtained.
Relations with business partners
The VNG Group develops strong, reliable relations with its business partners with a view to safeguarding long-term business success and avoiding damage to the reputation or financial position of the Group. In this approach, the careful selection of business partners is essential. The VNG Group has clear rules concerning the review of business partners which ensure that business partners are carefully selected and reviewed with respect to corruption and other compliance risks.
The Compliance Officer receives both internal and external reports concerning possible offences and other infringements of statutory requirements and guidelines. All such reports are treated strictly confidentially.